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National HMO Lobby



National Planning Policy Framework

Consultation Questions

1 "The Framework has the right approach to establishing and defining the presumption in favour of sustainable development." Strongly disagree

Paragraph 9: The National HMO Lobby considers that there is a tension within the National Planning Policy Framework's concept of 'sustainable development', between its understanding of 'sustainability' and its understanding of 'development'. 'Development' seems to be understood essentially in terms of 'economic growth' (see paragraph 13). 'Sustainability' however is understood in essentially social terms: paragraph 9 refers to "people … enjoying a better quality of life, both now and in the future." Meanwhile, paragraph 1 makes clear that one of planning's roles is to "support strong, vibrant and healthy communities"; and paragraph 5 emphasises that it is for "local people … to reflect the needs and priorities of their communities." In other words, both the end and the means of planning is strong communities, which is also apparent in the government's goal of a Big Society, and its route thereto through vehicles such as the Localism Bill. The Lobby therefore is concerned that the Framework quite fails to prioritise 'community' in general, and its foundation in 'housing' in particular.

Paragraph 10: This paragraph prioritises economic growth, planning for prosperity (bullet-point 1). However, if 'sustainability' is understood as it is in the Framework, then economic growth is not an end in itself, but a means to an end, "a better quality of life" for local communities. The priority should properly be given to planning for people (bullet-point 2), "supporting strong, vibrant and healthy communities." Unfortunately, this questionable initial prioritisation underlies the whole structure of the Framework.

Paragraph 13: The section is titled sustainable development, but paragraph 13 interprets this solely as "economic growth."

Paragraph 14 identifies the economic version of development as a "golden thread" running through the whole planning system. But if strong communities are both the means and the end of planning, then surely 'communities' should be the golden thread?

Paragraph 18 is welcome in re-asserting the priority of communities, "development is expected … to respond to the needs of communities."

Paragraph 19: The Lobby considers that the paragraph on Core Planning Principles is seriously deficient. Not one of the ten principles acknowledges the importance of communities: environment, heritage, greenspace, resources, transport, health, and so on, all are cited - but no reference is made to the key role of strong communities.

2 "The Framework has clarified the tests of soundness, and introduces a useful additional test to ensure local plans are positively prepared to meet objectively assessed need and infrastructure requirements." Neither agree nor disagree

Paragraph 25: The Lobby welcomes the emphasis on the engagement of local communities in plan-making.

Paragraph 28: The Lobby welcomes the priority given here to housing, which is the bedrock of communities. But the Assessments advocated should be concerned not only with demand (Market Assessment) and supply (Land Assessment), but also with the central role that mix, or diversity, plays in sustaining strong communities.

Paragraphs 49-52: The Lobby welcomes the Framework's emphasis on Neighbourhood Plans.

3 "In the policies on development management, the level of detail is appropriate." Neither agree nor disagree

Paragraph 53: The Lobby considers that the primary objective of development management should be to support sustainability.

Paragraph 57: The Lobby welcomes the support for the involvement of the local community in the pre-application stages of planning applications.

Paragraph 64-66: The Lobby welcomes the Framework's emphasis on local circumstances. (With regard to Article 4 Directions, it is important that planning applications generated by these should incur fees, so that they do not drain local resources.)

5 "The 'planning for business' policies will encourage economic activity and give business the certainty and confidence to invest." Neither agree nor disagree

Paragraph 71: The economy matters, of course, but the Lobby considers that it is not the same as 'development' in general, and it is a means to an end, not an end in itself. In the Framework, it should be preceded by planning for people.

Paragraph 74 reinforces the equation of 'economic growth' with 'sustainable development.'

6 "The town centre policies will enable communities to encourage retail, business and leisure development in the right locations and protect the vitality and viability of town centres." Neither agree nor disagree

Paragraph 76: The Lobby supports the promotion of town centres. Further to bullet-point 4, residential development is necessary for the viability of town centres; but strong communities surrounding the town centre are also necessary for viability and vitality.

7 "The policy on planning for transport takes the right approach." Neither agree nor disagree

Paragraphs 82-84 omit entirely the importance of transport in sustaining strong communities and maintaining community cohesion. It is important on the one hand to provide for free movement for all within communities, and on the other, to protect communities from the impacts of transport unrelated to those communities. In particular, paragraph 84 should add a third objective concerned with transport within communities.

Paragraph 92 points up the importance of local transport, but only in the context of new residential developments.

10 "The policies on housing will enable communities to deliver a wide choice of high quality homes, in the right location, to meet local demand." Neither agree nor disagree

Paragraph 107: The Lobby welcomes bullet-point 4, "creating sustainable, inclusive and mixed communities", as an essential objective of housing policy.

Paragraph 109, bullet-point 7, draws attention to one aspect of the abuse of existing housing stock, empty properties, especially significant when a major policy objective is to "increase the supply of housing." However, in a time of acute shortage, the Lobby is also concerned about the abuse of stock when it is used as a second home. This happens for a number of reasons - leisure is the most obvious reason (holiday homes), but so too is work (crashpads) and also study (student houses). Policies should be devised to meet these needs, not from existing housing stock, but from purpose-built development or from the conversion of other types of redundant buildings.

Paragraph 111: Mixed housing is mentioned in the first and last bullet-points of this paragraph. The Lobby recommends that it is identified as a criterion in its own right.

Paragraph 111, bullet-point 3: The Lobby welcomes the policies for affordable housing, especially the option of "financial contributions" (or commuted sums) to help create mixed and balanced communities. This is a vital measure where local communities (such as Headingley in Leeds) are seeking to redress polarisation of the neighbourhood, as the consequence of the conversion of first homes for families into second homes for students.
However, the Lobby regrets that the reduction of the Planning Policy Statements has led to the omission of "the national indicative minimum site size threshold [of] 15 dwellings" (PPS3, paragraph 9) in the requirement for affordable housing. This will undermine the provision of affordable housing, which is universally recognised as being in short supply.

Paragraph 124-132: The Lobby finds it deeply regrettable that the section on sustainable communities does not even merit a Question in the Consultation. In fact, communities should be the golden thread (paragraph 14) of the Framework - and as such, planning for people surely deserves priority over the other sections of the Framework.
Furthermore, given the importance ostensibly accorded to the role of 'community', the Lobby is surprised that no attention is given to the government's understanding of what constitutes 'community'. Since there are many kinds of community, it should at least be made clear that it is local communities which are meant (as opposed to communities of interest, for instance). Again, consideration should be given to the representation of communities: Parish and Town Councils are accountable to their electors, but what of urban communities without such councils? And in our cities, how are communities delineated? Finally, not all communities have the same degree of social capital: means should be found to ensure the equality and viability of communities.

Paragraph 125: Given the importance of mix and balance to sustain strong communities (paragraphs 107 and 111), the Lobby considers that one of the objectives of planning for inclusive communities should be to avoid polarisation. On the one hand, polarisation arises either from the exclusivity of the privileged, or from the exclusion of the disadvantaged; on the other hand, it loses the diversity of life-skills provided by a mixed and balanced community. For both reasons, it should be discouraged.

12 "The policy on planning and design is appropriate and useful." Neither agree nor disagree

Paragraph 116: The Lobby welcomes bullet-point 3 on local character, as an objective of design policy. Neighbourhood Design Statements, developed by the local community, provide a vehicle for doing so.

Paragraph 122: Where there is a local Neighbourhood Design Statement, developers should be encouraged to refer to this, and to liaise with the community which developed it.

Paragraph 123: The Lobby welcomes control of outdoor advertisements, which can blight a neighbourhood (for instance, letting boards erected in huge numbers in areas of HMO concentrations).

16 "This policy provides the right level of protection for heritage assets." Neither agree nor disagree

Paragraph 179: Neighbourhood Design Statements provide an alternative designation for neighbourhoods valued by their local communities

Dr Richard Tyler, National HMO Lobby, October 2011


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